Articles About Practice Management

As advisory firms seek to refine their fee structures and find ways to add value for (and generate new revenue from) their existing clients, one of the more interesting shifts in the industry over the past couple years has been away from billing on assets under management and towards assets under advisement, which are those outside held-away assets (e.g., a 401(k) plan at a current employer) on which an advisor may make recommendations, but not necessarily effect any transactions (because it’s not under their direct management). The appeal of such an approach is understandable: qualified plans are an ever-increasing piece of clients’ nest egg, especially for those in their 30s, 40s, and 50s, and the dilemma advisors often face is that, while a potential client might have significant net worth, much of that is tied up in accounts that the advisor can’t manage directly.

In this week’s #OfficeHours with @MichaelKitces, my Tuesday 1PM EST broadcast via Periscope, we discuss the ways in which advisors are working with clients with substantial held-away assets, the issues they may face when charging an assets-under-advisement (AUA) fee on outside assets, and some operational challenges that advisors need to think about before adding on this type of fee structure.

The quintessential example of a client where an AUA fee may be a better fit than an AUM fee is the still-working client with a moderate (e.g., $150,000) brokerage account, and a sizable (e.g., $350,000) 401(k) plan at a current employer, where the client can afford to pay the advisor a reasonable fee in the aggregate, but not necessarily “just” from the account that’s available to manage.

There are a few ways to handle situations like this. In some cases, the advisor simples takes the client on in hopes of getting that sizable roll-over down the road (even if it’s an unprofitable client for years up until that point). Others may set a minimum annual fee for clients if their available assets fall under a certain threshold, ensuring that there is a sufficient level of revenue per client to service the client, and letting those with sufficient net worth (even if not all available to manage) to decide for themselves whether to move assets, or just pay the fee.

The third approach that’s emerging, though, is simply to not charge only on the assets that the advisor manages directly, but also setting an assets under advisement fee for those outside held-away assets that might provide advice on, even if the advisor doesn’t (or can’t) have discretionary authority. For which the AUA fee is typically lower, recognizing that while the advisor does provide some services, it is less than the full-service management (for the full-service management fee) on the actual managed accounts.

However, charging an AUA fee it’s not without its potential pitfalls. In some cases, clients may not want to pay for “just” asset allocation advice they have to implement themselves. And if an advisor gets the client’s login credentials to do it for them, the service is a lot less cost efficient due to the added layers on manual work involved, and means that the advisor has custody of those assets (and as such, is subject to an annual surprise custody audit under the SEC custody rule). Moreover, if the client gets accustomed to paying a lower fee to have the outside 401(k) “advised upon”, they may not want to roll over and pay a full management fee when the time comes (if the advisor has not effectively distinguished the value). Which can be especially challenging for advisors with a more passive approach, since at least active managers can claim there is additional value in rolling over by being able to implement full investment management process (e.g., offering “tactical management of retirement assets to minimize sequence of returns risk”).

Beyond those challenges, advisors also need to figure out how they’re actually going to bill on those held-away assets. As since advisors generally can’t deduct fees directly from a 401(k) account, they will either have to bill from managed accounts they do oversee (which is bad news for the advisor’s performance numbers, since the fees for the entire pie and coming from just the advisor’s slice), or send the client an invoice and implement technology to bill them directly.

These challenges to adopting an AUA fee aren’t insurmountable, however, but do require some careful thought and planning in advance. As ultimately, charging a fee on assets under advisement may be a good way for certain advisors to expand their relationship with existing clients, especially those who are still in their working years and have a sizable 401(k) plan that is unavailable to be managed directly. However, the AUA fee has got to make sense from a business perspective as well, which means having a clear operational game plan for calculating fees, dealing with all the extra manual work, and for navigating the regulatory minefield.

The number of female CFP professionals has remained stubbornly pegged at 23% for nearly 15 years, despite an ever-growing effort of the industry to attract more women. Because unfortunately, even as the profession seeks to build awareness and draw more women into financial planning, the positive impact is limited by the amount of sexual harassment and demeaning and belittling comments still directed at women by “fellow” advisors at the typical advisory industry conference.

In this week’s #OfficeHours with @MichaelKitces, my Tuesday 1PM EST broadcast via Periscope, I share recent and unfortunate case-in-point examples of inappropriate and belittling comments that are still being made towards female advisors at industry conferences today, and explore what needs to be said to curtail problematic behavior.

For instance, at the recent FPA NorCal conference, a conversation that I was having with a group of female colleagues – including fellow advisors and several industry-leading consultants – was interrupted by another advisor who proclaimed the semi-circle of women I was speaking with looked like a “harem”. As though it’s ever appropriate to compare professional female colleagues to concubines!?

Similarly, it’s still all too common for women at advisory industry conferences to receive comments like “Whose assistant are you?” or “What do you actually do at your advisory firm?” with the implication that it couldn’t possibly be working as a financial advisor… even for a woman who prominently displays her CFP certification and a firm that’s named after her!

Yet I’ll confess that even as someone who has witnessed these kinds of disparaging comments, and am incredibly frustrated by them as well… I still struggle to figure out what, exactly, to say in order to break the cycle. As unfortunately, calling out offenders and trying to publicly humiliate them for their offensive comments is more likely to just make them defensive and run from the situation, instead of gaining some empathetic perspective and actually acknowledging and recognizing how their comments may be so demeaning to their female colleagues.

The bottom line, though, is that as someone who has witnessed this behavior, and often said nothing – out of a sheer lack of knowing what to say – I regret not taking a more active role in trying to stop it and saying something when I see or hear inappropriate behavior at advisory industry conferences. And it’s something I intend to address more proactively going forward. But I hope you’ll share your comments at the end of this article with your own perspective, on how best to have this conversation in the first place? What do you say when you witness sexual harassment at a financial advisor conference?

A custodian is one of the most crucial vendors for RIAs that manage client assets. From the core custodial services of trading and holding and keeping records of electronically-owned securities, to the ancillary technology that custodians provide to help advisors run their business, a good RIA custodial relationship can help firms attract and retain clients. However, as the advisory industry has shifted from a focus on sales to advice, custodians and the RIAs they serve are increasingly in conflict with one another, as many of the ways in which RIAs can help their clients reduce costs and further grow their wealth (reducing unnecessary trading costs, seeking out the best cash options, etc.) are actually detrimental to the bottom lines of the RIA custodians they use!

In this week’s #OfficeHours with @MichaelKitces, my Tuesday 1PM EST broadcast via Periscope, we discuss why RIA custodians should start charging the RIAs they serve a custody fee, and why a basis-point custody fee would ultimately better align the interests of RIAs and the custodians that serve them, allowing custodians to actually focus on providing the best services and solutions to RIAs, instead of just seeking new ways to make money off of an RIA’s clients instead!

To better understand why an RIA custody fee would be an improvement relative to the status quo, it is helpful to first look at how RIA custodial platforms actually make their money in the first place. In practice, most RIA custodians make money in three ways: (1) earning money on cash (either through the expense ratio of a proprietary money market fund, or by sweeping the cash to a related bank subsidiary), (2) servicing fees for mutual funds and ETFs, such as sub-TA fees along with 12b-1s via “No Transaction Fee” (NTF) platforms, and (3) ticket charges earned whenever a client makes a trade. In practice, many of these fees may ultimately be trivial to the end consumer (e.g., it’s unlikely a 50 basis point fee on a 1% cash position is going to make or break a client’s retirement), but when companies like Charles Schwab have almost 1.5 trillion dollars on their RIA platform, these expenses result in substantial revenues for RIA platforms when aggregated across all clients… albeit at the direct expense to the client.

And the reason this structure matters is that it means RIA custodians are fundamentally misaligned with the advisors they serve. Because a situation is created where we as RIAs create value for our clients by trying to systematically dismantle the custodian’s revenue and profit lines! Instead of just leaving cash in whatever money market fund is available, we look for ways to reduce cash balances or shift that cash to institutions that best compensate our clients for holding cash. Instead of using an NTF fund with a higher expense ratio, we’ll shift our client’s assets to a non-NTF fund when the ticket charge will reduce costs for them (or vice-versa). And unlike broker-dealers who stand to profit from increased trading (by marking up the ticket charges for themselves), RIAs try to reduce trading costs by helping clients avoid unnecessary trading. In short, the problem is that as RIAs, custodians have put us in the position where we look better by sticking it to the custodian… and the more we manage to ‘play the game’ and dismantle the custodian’s profit centers, the more money we save our clients, and the better we look to our clients!

And this is why the future of the RIA custody business will eventually be RIAs simply paying a basis point custody fee to the RIA custodian instead. Which is a huge leap relative to the “free” that we as RIAs currently enjoy with our custodians… but basis point custodial fees would actually be better for all of us in the long run! Suppose RIA custodians charged 10 basis points, tiering down to 7, 5, and then 3 basis points for large firms (intended to simply approximate what they already make off of RIA clients on average). If custodians did this in lieu of making money off of our clients, now their incentive is not to try and figure out how they can make more money off of our clients, but instead to truly create the best RIA custody platform out there for gathering client assets! With a custody fee in place, RIA custodians could then pay better rates on money market funds, eliminate ticket charges that annoy our clients (and time spent by advisors devising ways around ticket charges for our clients), and eliminate both 12b-1 fees and sub-TA fees, instead providing a new version of truly “clean shares” that strip out all back-end fees (regardless of what fund company is used). In other words, once the RIA custodian gets an RIA custody fee, the custodian is freed up to actually give us as advisors the best possible solutions for our clients!

Of course, there may be some challenges in getting RIAs to adopt such a model, particularly given that a subset of RIAs – namely those that use buy and hold portfolios for clients and actively seek ways to get clients the best deal on cash holdings – are already paying less (as they’re effectively subsidized by the RIAs that do not use such strategies!).

But the bottom line is just to recognize that, in the long-run, both RIAs and the custodial platforms they use would be better off with custodians charging a basis point custody fee, rather than just looking for ways to make money off of our clients. Even though it may feel really awkward to us when we’re not using to paying that custody fee, it will ultimately be better, both for the custodian and for the RIA itself, by properly aligning their interests… which means, in the end, it’s better for the client, too!

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In recent weeks, you may have noticed a wave of “Privacy Policy updates” coming through your email inbox. What financial advisors, and particularly those of us in the US, may be less knowledgeable of, is what’s driving these updates. The answer is the “General Data Protection Regulation” (GDPR), which is a new set of laws that govern internet privacy in the EU, and will go into effect this week on May 25, 2018. And while it may seem that privacy regulation in the EU is irrelevant to US advisors – who are not based in the EU – the reality is that if you have any clients in the EU, you market your services to clients in the EU, or you have clients who will be moving to the EU, then you are subject to GDPR as well! And there is some debate that even merely having EU web traffic that you’re tracking on your website could trigger GDPR rules for US financial advisors!

In this guest post, Zach McDonald of Mineral Interactive shares his thoughts on how US financial advisors can remain compliant with EU laws as GDPR goes into effect, including understanding the rights of consumers guaranteed under GDPR (e.g., the right to be forgotten, right to have access to personal data, right to grant or deny services consent, and the right to grant or deny placement of cookies), the advisors potentially impacted under GDPR (including any advisors who work with or solicit clients in the EU, and potentially even those who may merely have EU web traffic), the steps advisors can take to become GDPR compliant (from getting permission to track cookies, to verifying that vendors are compliant, and more), and the tools advisors commonly use that could also create GDPR issues (such as appointment schedulers, landing pagers, and many others)!

Ultimately, though, the key point is to acknowledge that advisors in the US cannot simply ignore GDPR as something that only applies to those in Europe. Many advisors in the US could fall under GDPR, due to something as minor as a single existing client who moves to Europe. And until we see how the EU will enforce the regulations, there is a risk that even just getting EU web traffic (whether the advisor wants it or not!) could trigger GDPR issues. As a result, advisors overlook GDPR compliance at their own risk, as failure to comply with GDPR can lead to substantial EU fines! And given the recent scandals and large-scale breaches of consumer data in the US – such as those at Facebook and Equifax – there’s also the possibility that GDPR could simply serve as a bellwether of changes to come here in the US as well! (Which means we may all be subject to GDPR-like rules soon enough!)

A considerable challenge for financial advisors providing standalone fee-for-service financial planning advice is figuring out the “right” price that is both profitable to the advisor, and attractive to consumers. Notably, this is a challenge that largely did not apply to past generations of advisors, who typically either just sold products with commissions (that were determined by product manufacturers and not chosen by the advisor anyway), or charged an AUM fee (in which there was strong convergence on the 1% price point for all advisors). As a result, fee-for-service advisors who are aiming to reach clients through a different compensation model have both an opportunity to expand service into previously unserved markets (particularly those prospective clients who cannot be reached through traditional advisor business models like commissions or AUM), but also a challenge in needing to take more responsibility for determining how to price their services in the first place.

In this guest post, Alan Moore of XY Planning Network and AdvicePay, shares his thoughts on how to profitably price a fee-for-service financial planning offering, including the options for calculating financial planning fees (e.g., flat fee, hourly, project-based, percentage of net worth and income), the structure of paying advice fees (e.g., one-time fees, ongoing fees, or a combination), setting the right advice fee frequency (e.g., monthly, quarterly, semi-annual, annual), how to integrate some combination of fee-for-service and AUM fees (for firms that are looking to transition from an existing AUM model), how to make sure your fees are both profitable for the advisor and reasonable for your (niche) clientele!

Ultimately, though, the key point is to acknowledge that like the massive shift from commissions to AUM over the past few decades – which allowed advisors to serve clients in a fundamentally different way and reduced certain conflicts of interest – the opportunity to provide fee-for-service financial planning allows advisors to continue to evolve their business models, profitably serving an ever-increasing range of clients with fewer conflicts of interest. Yet the freedom and flexibility of the fee-for-service model does present new challenges in setting an advisory firm’s fees in the first place… even as advisors with a fee-for-service financial planning model are poised for success in serving the next generation of clients (who are eager to receive real financial advice, but want to pay for it directly!)!

As financial advisors – like any business owner – we want our clients to have a “great experience” when they do business with us, providing a high level of service and proactive communication. Yet the challenge is that what constitutes the “right” level of communication and engagement with clients will itself vary by the client, making it difficult to standardize “good service” across the entire firm. And ultimately, it’s hard to differentiate on good service anyway, as virtually all advisory firms like to pride themselves on providing “good service” to their clients. Which means if we truly want to provide an extraordinary service to our clients, we must go beyond just great service and think much deeper about what an extraordinary “client experience” truly is.

In this guest post, Julie Littlechild of Absolute Engagement (a firm that helps advisors craft a client experience that makes them attractive to the right clients) shares her 11 action steps that advisory firms can take to design their own extraordinary client experience, recognizing that the key to a create experience starts with clearly understanding who the firm is trying to serve (and not trying to serve) in the first place, and then crafting a plan to execute the plan profitably. Though ideally, it’s not just about segmenting clients, creating a service matrix for the firm to follow, and assessing capacity and profitability, but also better defining what your target clientele or niche is in the first place, and then working with them to co-create the client experience and map out the client journey, along with the supporting client communications plan and necessary business infrastructure.

Ultimately, though, the key point is simply to acknowledge that what we tend to think of as delivering great service in an advisory business is simply too narrow when it comes to really defining experiences, and great service alone isn’t the differentiator it once was. A broader and more holistic client experience really can differentiate a firm, but only if the firm clearly understands who it wants to serve, so it can create an extraordinary client experience for that particular target clientele. Because in the end, it’s not about finding the one particular tactic that is going make the difference, but instead, the building of a strong foundation that supports a specific target clientele and is consistent with the client’s journey that truly makes a client’s experience extraordinary!

Most financial advisors spend relatively little on outbound marketing – which isn’t entirely surprising, given how hard it is to differentiate and stand out in a crowded marketplace. To the extent that financial advisors spend at all on marketing, it tends to be little more than 1% to 2% of revenues, most commonly on client appreciation events for their existing clients (and, perhaps, a few potential referrals).

Yet arguably, the primary reason that it’s so hard to market as a financial advisor is that we choose to market ourselves as undifferentiated generalists, rather than targeting a particular niche or specialization. Because the reality is that once you choose a specific target market, it becomes far easier to identify specific, targeted marketing strategies that can have a favorable return on investment. Once the financial advisor doesn’t have to fight as hard to differentiate in the first place.

For instance, an advisor targeting retiring architects might join the American Institute of Architects, write a guest post for the EntreArchitect blog, speak on the Business of Architecture podcast and for conferences of architects, while volunteering on Architect association committees and forming relationships with architect-specific centers of influence. For which the financial advisor will likely have little competition at all… because few other financial advisors go deep into the architect (or any other) niche.

In fact, one of the key benefits of targeting a specific niche is the opportunity to take advantage of unique marketing channels that may be highly effective at reaching that particular niche. And in a more cost-effective manner than the broad-based, generalized marketing that most financial advisors have long since found to be ineffective. Because whatever the niche is, there will be some combination of association and/or community organizations, conferences and events, magazines and blogs, and other marketing channels that are specific to that niche, where the financial advisor can focus their marketing efforts for greater return on investment.

Historically, financial advisors didn’t actually have much control on the prices they charged clients, as financial plans were compensated by the products implemented pursuant to the plan… and the commission payout rates on those products were set by the product manufacturers (insurance companies or asset managers) with payouts controlled by broker-dealers and insurance agencies. It’s only been in recent years, with the rise of the Registered Investment Adviser, where RIAs can actually control and set their own AUM and financial planning fees, that suddenly advisors must actually figure out if their AUM, hourly, retainer, or other pricing model is “competitive” to the marketplace and appropriate given the services they provide!

In this week’s #OfficeHours with @MichaelKitces, my Tuesday 1PM EST broadcast via Periscope, we explore how to determine if you have the “right” pricing for your services by tracking your prospect conversion rates, why your fees should be too expensive for at least some of your prospects, and why there is such thing as having “too high” of a close rate with prospects!

Though the marketplace has increasingly converged on the “common” price point of a 1% AUM fee, when it comes to fee-for-service financial planning (e.g., hourly, standalone projects, and retainer fees), it’s hard to look at what other advisors are charging, because there aren’t many advisors doing fee-for-service planning in the first place, and we’re all so varied in the services that we do provide, that it’s difficult to compare anyway. Some advisors will back into a price based on the income they desire and the time (billable hours) they can put into the business. Others will price based on the perceived value to the client. But another approach still is to look at what your clients (or really, prospects who become clients) are willing to pay, based on what they actually decide to pay (or not) in hiring you!

The key metric to track to understand whether your financial planning fees are priced appropriately is your prospect conversion rate – i.e., how many of your prospects become clients. Notably, this doesn’t include leads who were not “qualified” (e.g., those who do not meet your asset or other fee minimums), because it’s really about how many people who are qualified to work with you ultimately choose to do so. Thus, if you meet with 15 prospects, of which 10 are qualified, and 3 of them do business with you, your conversion rate is 30% (which is 3 out of 10 qualified prospects). And this number matters because it’s a direct statement about whether your value proposition is being perceived as worthwhile by your prospects. Simply put – if your pricing is compelling, you tend to have a pretty high close rate!

In this context, you can think about prospect conversion rates in four tiers: Tier 1 (<25%), Tier 2 (25-50%), Tier 3 (50-75%), and Tier 4 (>75%). For those in Tier 1 (<25% conversion rate), there is a real problem; it may be that your pricing is too high for your value proposition (a pricing problem), or it could be that you’re not doing a good job conveying your value proposition (a sales problem), but something needs to be changed. Tier 2 (25-50% conversion rate) is where most advisors are, and the fact that you’ve gotten to at least a 25% conversion rate is evidence your pricing is reasonable. The caveat, though, is that many advisors in this category don’t feel very good about their conversion rate (since more than half of people you talk to are telling you “No”), but the reality is that your pricing can’t be that far off if 25% of people are telling you “Yes”, so the key here is to focus on improving sales skills to boost this conversion rate (but don’t cut your pricing to grow faster, since your fees are reasonable!).

When it comes to Tier 3 (50-75% conversion rate) advisors, there are really two types. The first is an advisor with some kind of recognized niche or specialization. This type of advisor is arguably in the conversion rate “sweet spot”, as it is virtually impossible to get everyone to do business with you, but the majority of prospects really are hiring you and demonstrating they see value relative to your fees. However, the second type of advisor in this category is an advisor who was a Tier 2 advisor, but rather than refining their marketing or sales process, simply cut their fees to increase their conversion rate. This type of Tier 3 advisor is in a problematic long-term situation, as pricing aggressively low just means you are eventually going to have trouble being able to afford to hire more staff and scale your business.

The final category of advisors, Tier 4 advisors (>75% conversion rate), can also be surprisingly problematic. Most advisors who close “virtually all” of their prospects are proud of it, but my advice for advisors in this category is to raise your fees! Because, in practice, the reality for these advisors is that if clients are this happy with your pricing, they’ll probably still be pretty happy with a higher price… and an increase in fees should boost revenue from clients who are willing to pay more far more than it will reduce revenue from a few more clients who might say no. Which means these advisors can end up making more money (as higher fees more than offset the slight reduction in new clients) but doing less work (because there are fewer new clients!) if they adjust their pricing.

Ultimately, though, the key point is to recognize that your prospect conversion rate is an important metric for determining whether you are priced properly. And if you aren’t keeping track of this metric, it only takes three numbers to keep track going forward: the number of leads you get, the number of qualified prospects amongst those leads, and the number of those prospects that turn into clients. From those numbers, you’ll be able to tell if you are pricing your services appropriately, and, if you need to make some adjustments, what those adjustments might be!

Advisors who are interested in starting their own advisory firm, or breaking away from an existing one, face a number of important business decisions – from how they want to structure their firm, to what clientele they will target, what software they will adopt, and when/whether they want to hire staff or outsource certain responsibilities. For advisors who want to provide investment management services to their clients, though, and intend to play an active role in managing and implementing client portfolios, one of the most important decisions they face is which RIA custodian they should work with.

In this week’s #OfficeHours with @MichaelKitces, my Tuesday 1PM EST broadcast via Periscope, we explore how to choose the best independent RIA custodian for your business, including the advantages of working with one of the “Big Four” custodians (Schwab, Fidelity, TD Ameritrade, and Pershing Advisor Solutions), as well the reasons why some firms may find a better fit among smaller “second-tier” custodians with more niche offerings for certain types of RIAs!

The first thing to consider when contemplating an RIA custodial relationship, is whether a custodian is actually needed in the first place. For advisors who are simply going to charge financial planning fees, and bill clients with a third-party payment processing solution for those finanical planning fees, and while letting clients continue to be self-directed with their actual portfolios (or serve clients who simply don’t have portfolios to invest), then the advisor does need to become an RIA, but doesn’t necessarily need an RIA custodian. However, given the dominance of the AUM model, and the number of advisors who do want to manage investments, most independent RIAs will ultimately form a relationship with one or more of the top RIA custodians.

For those independent RIAs that do need to use an RIA custodian, the overwhelming majority ultimately custody their assets at one of four major firms: Schwab, Fidelity, TD Ameritrade, and Pershing Advisor Solutions. Due to their sheer size and market reach, these providers all already provide the core technology necessary to trade in client investment accounts, hold a wide range of standard investment assets, facilitate the advisor’s AUM billing, and do it all at an incredibly low cost. In fact, there is generally no platform fee to work with these custodians at all, and instead these platforms make their money indirectly through ticket charges, asset-based wrap fees, 12b-1 and similar revenue-sharing fees via their NTF (No Transaction Fee) platform, receiving a fee for serving as the transfer agent, or making a small spread on the money market or other cash positions that clients hold.

Notwithstanding how commoditized the core services of an RIA custodian have become, though, each does still have its own style or area of focus. Pershing Advisor Solutions aims to work primarily with larger RIAs that are specifically focused on growing a large enterprise business. TD Ameritrade is known best for their VEO One platform, which essentially functions as an open architecture hub that most other advisor technology can integrate into. Fidelity is increasingly being known for their Wealthscape platform, which is increasingly being positioned as a “true” all-in-one platform, especially for comprehensive wealth management firms that combine together investment management and financial planning. And Schwab, as the largest of the four, is arguably the least differentiated, but handles the widest range of firms with what is usually the lowest cost, in part because they’ve literally been doing it longer than (and are larger with more scale than) any of the other RIA custodians.

Despite the popularity of the Big Four custodial firms, there are also a wide range of “second-tier” custodial firms (meaning “second-tier” in terms of size, not necessarily quality) that offer solutions for many independent RIAs. Shareholders Service Group (SSG) is a platform that is actually built on top of the Pershing platform, but SSG specifically services the “small RIA” marketplace, and may be of particular interest to newer firms which do not meet the typically $10 to $20 million AUM minimums of many custodians (including zero-AUM startups). TradePMR is particularly well known for their EarnWise mobile solution that allows you to manage most of your investment needs as the advisor directly from a smartphone or tablet. Trust Company of America is best known for their really efficient model-based trading tools, appealing to both advisory firms that systematize their investment process, and TAMPs that serve other RIAs. Folio Institutional is also known for being a particularly tech-savvy platform, for advisors that want to be completely paperless, and have good tools to manage model portfolios, as well as those who work with smaller clientele where Folio’s ability to trade fractional shares is very appealing. Apex Clearing is a newcomer that is actually so “tech-savvy” that they’re basically just a giant lattice-work of technology APIs that communicate with other advisor technology APIs, but without much of an “interface” layer on top (and as a result, most independent RIAs that work with Apex will work with them through another middleware provider like RobustWealth, AdvisorEngine, or InvestCloud to replace the kind of advisor dashboard and workstation that most of the other RIA custodians already provide). Other notable firms include Millennium Trust Company for RIAs that do a lot of alternative investing, and National Advisors Trust Company for firms that do a lot of trust business (and/or want the opportunity to be a shareholder in their platform).

Of course, even once you narrow down your potential RIA custodian options based on fit, it’s important to spend some time really looking at their technology, and their investment options, and make sure that their core systems really do fit what you do, how you serve your clients, and how you want to do business. But the key point is to acknowledge that no single custodian is best for all advisors, and given the substantial costs of switching from one RIA custodian to another, it is worthwhile to try to figure out upfront which custodian is the best for you, and not just in the short-term, but ideally in the long-run too!

For decades, financial planning was compensated primarily by the insurance or investment products that were implemented at the end of the plan. But as advisors increasingly become more financial-planning centric, and bring financial advice to clients who don’t necessarily want or need to implement products – they just want the advice – there is a growing desire from many advisors to simply get paid directly for the financial planning advice they provide and the plans they deliver. With the caveat that technically, it’s not permissible to be paid a standalone fee for financial planning advice as a broker or insurance agent!

In this week’s #OfficeHours with @MichaelKitces, my Tuesday 1PM EST broadcast via Periscope, we explore how advisors are licensed to deliver financial advice, why you can’t receive fee-for-service compensation through a broker-dealer or insurance agency, and how you must be registered in order to get paid a planning fee (if your firm will allow it!)!

Most “financial advisors” are licensed and registered in one of three ways: either you are a registered representative of a broker-dealer, an agent of an insurance or annuity company, or you are an investment adviser representative (IAR) of a Registered Investment Adviser (RIA). These licenses dictate what advisors can, and cannot, do, and how they may be legally compensated: if you have an insurance license, you can sell insurance… If you have a securities license, you can sell securities… And if you have a license to be an investment adviser, then you can “sell” (and get paid for) investment advice.. Of course, some advisors are licensed multiple ways, but the fundamental point is that technically, getting paid for advice is only associated with the third category: having your Series 65 and being an IAR of an RIA.

As a result, advisors increasingly are becoming dually-registered with their broker-dealer and a corporate RIA, or operating as a hybrid with their own standalone independent RIA separate from their broker-dealer in order to get paid for their financial plans. Because again, you do need to be associated with an RIA to get paid for financial advice… though when you’re also with a broker-dealer, it must be disclosed to a broker-dealer as an Outside Business Activity, which in turn must be approved by your B/D). Which means in practice, not all advisors at a broker-dealer can actually charge for a financial plan, either because the broker-dealer does not have a corporate RIA, won’t allow the advisor to have an outside RIA as an OBA, or both. And even broker-dealers that do permit such activities still have the ability to decide which advisors will be approved to do so… and how.

As a result, the ability to become dual-registered and operate under the broker-dealer’s corporate RIA, or have your own independent RIA as a hybrid, is increasingly turning into a differentiator itself in the selection of a broker-dealer. Which has implications both for the control that the advisor has over their financial planning services and compliance oversight, and also the financial split of the fees between the broker-dealer and the advisor. Not to mention the technology that the advisor can, cannot, or must use to process those financial planning fees.

Nonetheless, the fundamental point is that if you’re at a broker-dealer or an insurance agency, and you want to actually get paid directly for a financial plan and giving financial advice, you need to operate under an RIA. It can be your broker-dealer’s corporate RIA, or your own independent RIA if your broker-dealer will allow it (or you can just break away from the broker-dealer and start your own RIA), but one way or another, you need to pass your Series 65 and be affiliated with an RIA if you are going to receive “fee-for-service” compensation for financial advice!